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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 107 prematurely. Chronic exposure can lead to asthma and chronic obstructive pulmonary diseases (COPD), and is particularly damaging to children, active young adults who spend time outdoors, and the aged. Ozone combined with particular matter less than 2.5 micrometers produces smog (haze) that has been demonstrated to be harmful to humans as measured by emergency room admissions during periods of elevation. Gas field produced ozone has created a previously unrecognized air pollution problem in rural areas, similar to that found in large urban areas, and can spread up to 200 miles beyond the immediate region where gas is being produced. Ozone not only causes irreversible damage to the lungs, it is similarly damaging to conifers, aspen, forage, alfalfa, and other crops commonly grown in the West. Adding to this air pollution is the dust created by fleets of diesel trucks working around the clock hauling the constantly accumulating condensate and produced water to large waste facilities evaporation pits on unpaved roads. Trucks are also used to haul the millions of gallons of water from the source to the well pad.293 As discussed, development under the UFO RMP/EIS will increase ozone. The BLM acknowledges: “The magnitude of estimated emissions from BLM-authorized oil and gas activities at the level of development predicted over the life of the RMP in Alternatives A, B, B.1, C, and D have the potential to contribute to increased ambient concentrations of ozone in, adjacent to, and outside and downwind of the planning area.” DEIS at 4-20. Research indicates a strong correlation between oil and gas development and increased ozone concentrations – particularly in the summer when warm, stagnant conditions yield an increase in O3 from oil and gas emissions.294 Particularly in areas of significant existing oil and gas development – such as heavily developed portions of the Piceance Basin, but also the San Juan Basin, which was the subject of this research – summertime “peak incremental O3 concentration of 10 ppb” have been simulated. Id. at 1118. This study indicates a “clear potential for oil and gas development to negatively affect regional O3 concentrations in the western United States, including several treasured national parks and wilderness areas in the Four Corners region. “It is likely that accelerated energy development in this part of the country will worsen the existing problem.”295 Additionally, and as mentioned above, oil and gas production in the mountain west has recently been linked to winter ozone levels that greatly exceed the National Ambient Air Quality Standards (“NAAQS”).296 293 Theo Colburn et al., Natural Gas Operations from a Public Health Perspective, available at: http://endocrinedisruption.org/assets/media/documents/GasManuscriptPreprintforweb12-5- 11.pdf (attached as Exhibit 151). 294 Marco A Rodriguez, et al., Regional Impacts of Oil and Gas Development on Ozone Formation in the Western United States, JOURNAL OF AIR & WASTE MANAGEMENT ASSOCIATION (Sept. 2009) (attached as Exhibit 152). 295 See Rodriguez at 1118. 296 See Gail Tonnesen and Richard Payton, EPA Region 8. Winter Ozone Formation: Results from the Wyoming Upper Green River Basin Studies and Plans for the 2012, Uintah Basin Study (seminar abstract) (Jan. 2012), available at: http://www.esrl.noaa.gov/csd/seminars/2012/TonnesenPayton.html (citing, inter alia, Schnell, et. al., Rapid photochemical production ozone at high concentrations in a rural site during winter, 2